STATE OF FLORIDA DEPARTMENT OF HEALTH ‘DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: 98-08542 DONNA LEE PARSONS COLARUSSO RESPONDENT. ADMINISTRATIVE COMPLAINT. COMES NOW, the Petitioner, Department of Health, hereinafter referred to as ’ “Petitioner,” and files this Administrative Complaint before the Board of Nursing against DONNA LEE PARSONS COLARUSSO, hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency ‘charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 464, Florida Statutes. Pursuant to the authority of Section 20.43 ' (3)(£), Florida Statutes, the Petitioner has contracted with the Agency of Health Care “ Administration to provide consumer complaint, investigative, and prosecutorial s services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. _ Respondent i is, and has been at all times material hereto, a licensed PRACTICAL Nurse in the st state of Florida having been issued license number PN 1032911, . Respondent's last ‘known address is 8906 Monroe Ave., J acksonvill FL 32208. 3. ‘Atall times material hereto, Respondent was employed by Mariner Health. we id 4. On or about December 30, 1997, resident LR was admitted to Mariner Health _ witha cyanotic left foot. LR’s right leg had been previously amputated. 5. On or about December 30, 1997, through January 21, 1998, Respondent was responsible for monitoring the condition of LR's left foot at least three times a week. 6. On or about December 30, 1997, through January 21, 1998, Respondent documented that she performed assessments of LR's left foot on the Treatment Charting Form. 7. On or about December 30, 1997, through January 21, 1998, Respondent failed to document the deteriorating condition of LR’s left foot in her Nursing Notes. 8. _ Onor about. February 1, 1998, LR was diagnosed with gangrene of her left foot, . and subsequently had her left leg amputated. —&#u On or about December 30, 1997, through January 21, 1998, Respondent should have recognized and documented the deteriorating condition of LR's foot in her nursing notes. Based on the f - 10. , i 2, Respondent is subject to discipline pursuant to Section - 464. 01 181), Florida Statutes, unprofessional conduct as s defined by Rule 64B9- 8. 005(1Xe)1. F Jorida Administrative Code, byi inaccurate recording, falsifying or altering of patient records or nursing Progress records, employment records or time records. - " WHEREF ORE, Petitioner respectfully requests the Board of Nursing enter an order n of the Respondent's s “arep P deems appropriate. 1999. _ TEE MEE TET ITE ie “amapmmmeyesitaienmmmanrre emer ne erage te pun ve COUNSEL FOR PETITIONER: Chris Steinhaus, Attorney Florida Bar Number - 0147966 Agency for Health Care Administration ‘Allied Health P.O. Box 14229 Tallahassee, FL 32317-4229 (850) 414-8576 - CJS/cjs ~ PCPRELBL DATE: calel aS W ’ Robert G. Brooks, MD Secretary, Department of Health : Nancy M. Snurkowski Chief Attorney Agency for Health Care Administration FILED DEPARTMENT OF HEALTH no art peguaprergiee—ere

Docket for Case No: 00-001055